The Mold Remediation Standard of Care: Does It Work? Restoration

$9.00
January 2012 • Vol. 49 No. 1
Published by the Restoration Industry Association
A Fire Marshal Talks to Restorers
The Mold Remediation
Standard of Care: Does It Work?
Restoration Rescue:
Condo Case Study
Computer-Based Testing:
Wave of the Future
Mold Remediation
ACCORDING TO THE STANDARD OF CARE:
?
Does It Work
By Mark McLaughlin, CMP
D
uring my career, I have done several small experiments to test theories and equipment. I have also been
exposed to several ways of performing mold remediation, with each one proclaimed “the best” by its
practitioner. In early 2010 I applied for the CMP program, and the
seed was planted for my largest experiment ever.
I started my CMP path by attending Wonder Makers
Environmental courses taught by Michael Pinto, the author of the
textbook and designer of the CMP program. During these courses,
I learned information and techniques that I adopted here at Restore
All, Inc. I was pleased with the results, but I kept wondering if the
practices made a difference.
I was also surprised at how the standard of care differed
depending on the authoring agency and that not all mold projects
were treated the same. Specifically, my skepticism grew regarding small projects that were supposedly okay to remediate with no
engineering controls at all.
I examined the three priorities for fungal contamination work as
described in Fungal Contamination: A Comprehensive Guide for
Remediation:
1. Protect yourself and the crew.
2. Protect the building occupants.
3. Protect the building and contents.
I decided that my CMP capstone would be to test the methods we use and to evaluate how we were meeting these
28 Cleaning & Restoration | January 2012 | www.restorationindustry.org
priorities in a controlled environment. Passing post-remediation
testing was not a goal of this project. I was far more concerned
with what we are doing during remediation to our people and
the surrounding structure. There is no permissible exposure
limit for mold, so shouldn’t we do our best to minimize the airborne spore counts during our work to protect our people, the
building and its occupants? Air samples are pulled continuously
during asbestos projects. Why not try it with mold and see what
we find out?
I wanted to know:
•
•
•
•
Do my current remediation methods work?
Does the chemical matter? If we followed all of our normal
work practices but switched the chemical we use, would it
be reflected in the air sampling?
Do engineering controls matter? Most of my experience
was with minimal engineering controls. Why use dust control tools such as vacuum attachments during cutting? Why
cut and bag immediately instead of letting debris pile up?
Why vacuum seal and spray down debris bags? Does any
of this make a difference?
What was the validity of the “less than 10 sf” rule? Why
don’t you need negative air, containment or PPE? Is there
cross-contamination occurring? How many restoration
companies, maintenance personnel and others live and die
by this rule, yet no one has ever tested it?
ROOM 1: THE CONTROL
Remediation in this room was performed in the way we handle
every mold job.
We had a zipper door on the entry to the structure. Also
attached was a single-stage decon with a reverse T-flap door.
Inside the decon chamber, we had a tool pouch containing tape
and other small tools. The room was under negative pressure
during the entire project.
Here are the steps we took:
1
2
An initial HEPA vacuum of the entire room.
3
4
Another HEPA vacuuming of the entire room.
5
6
Final HEPA vacuuming of the entire room.
Photos courtesy of Mark McLaughlin, CMP
DESIGNING THE EXPERIMENT
Now that I knew what I wanted to do, I had to figure out how to do
it. I told Pinto about my idea. He and the team at Wonder Makers
agreed to send me a Wonder Air sampling pump and lots of sample
cassettes and to process the ridiculous amount of samples I would
be taking. They also helped me fine-tune my goals and taught me
how to effectively sample the project.
Next came the structure. We needed to build four identical 12x12
rooms. The rooms were all stick-built like a typical house. Each
room had one door opening and one window built into it. The main
difference from standard building practices was the drywall installation. Upon Pinto’s suggestion, we hung the drywall with the paper
facing outward to speed up mold growth.
I decided to sample:
• In the decon chamber;
• In the work area;
• During all stages of work, including initial vacuum, cutting
and demo, bagging debris, second vacuum, wipe down, and
final vacuum; and
• Before-and-after work in the warehouse to get a baseline
and to establish if we affected air quality at all.
Removal of all visibly contaminated drywall. This was
done with a rotozip tool with a HEPA vacuum attachment to minimize airborne particulates. All debris was
cut into small pieces and bagged upon removal without the debris ever touching the floor or being allowed
to accumulate. All trash bags were vacuum-sealed
and gooseneck-tied with a tape seal. We also sprayed
all debris bags with Microban before removal to
knock down any particulates that might have adhered
to the bag.
The “wipe down” phase. All surfaces from drywall
to wood were scrubbed with green scouring pads
soaked in a Ready To Use (RTU) Microban solution
and then wiped down with cotton towels using the
same solution.
Vacuum and wipe down of all of our equipment,
including the HEPA negative air machine, the vacuums themselves and all tools. We also lightly misted
all plastic with Microban, including the plastic lay-flat
duct attached to the negative air machine, our zipper
door and the inside of our decon chamber.
Air samples were taken continuously both in the work area
and in the decon chamber. Total fungal structures were
www.restorationindustry.org | January 2012 | Cleaning & Restoration 29
relatively low during the project but spiked during work practices to
as high as 165,709 (c/m3) during the bagging of debris. The highest
count we got in our decon chamber was 3,242 (c/m3). This occurred
during our second HEPA vacuum immediately after the removal of the
bagged debris through the decon chamber.
We finished the project with a count of 1,963 (c/m3) in the work
area and 360 cm3 in the decon chamber. Our pre-remediation sample
was 6,584 (c/m3), so we had obviously decreased the spore count.
After remediation, we followed the same steps on each structure (with
the exception of Room 4). We detached the decon chamber, sealed the
zipper door, attached a pleated filter to the plastic on the zipper door
to allow exchange air through and continually ran the air scrubber. Our
final sample revealed a total fungal count of 44 (c/m3) and passed the
Wonder Makers’ recommended post-remediation criteria.
ROOM 2: ASSESSING
ENGINEERING
CONTROLS
We tested the effectiveness of engineering controls by
removing controls that might be considered overkill by most
contractors. Our goal was to see how much of a difference
these engineering controls make.
For cutting drywall, we abandoned dust control tools and
went to a Sawzall and a hand-held drywall saw, neither with
any vacuum attachments. We did not vacuum trash bags or
spray them down. We let debris and trash pile up in the work
area, as is typically done. We did not treat any plastic with
chemicals.
Here are the steps we took:
1
2
3
4
5
6
An initial HEPA vacuum of the entire room.
Removal of all visibly contaminated drywall. This was
done with a Sawzall or drywall saw.
Another HEPA vacuuming of the entire room.
The wipe-down phase. All surfaces from drywall
to wood were scrubbed with green scouring pads
soaked in an RTU Microban solution and then wiped
down with cotton towels using the same solution.
Final HEPA vacuuming of the entire room.
Vacuum and wipe down of all equipment, including
the HEPA negative air machine, the vacuums themselves and all tools.
Room 2 had a pre-remediation total fungal count of
103,000 (c/m3). The spore counts were so elevated
during the work in this unit that it was almost impossible
for the lab to quantify the numbers. During debris bagging,
the count was as high as 2,207,200 (c/m3) in the work
area and a concerning 15,888 (c/m3) in the decon chamber. Our post-remediation sample was 88 (c/m3) and
would pass the Wonder Makers’ recommended post
remediation criteria.
30 Cleaning & Restoration | January 2012 | www.restorationindustry.org
ROOM 4: ASSESSING
THE 10 SF RULE
Remediation was performed in accordance with guidance
from the OSHA standard for areas of mold that are less than
10 visible square feet. We had no containment, air scrubbing
or negative air of any sort.
We took the following steps:
1
2
3
4
5
ROOM 3: ASSESSING
CHEMICALS
Remediation in this room mirrored the process used in Room 1.
However, we used IAQ hydrogen peroxide for cleaning instead
of Microban.
Our pre-remediation sample in this room revealed a total fungal
count of 249,742 (c/m3). While total fungal counts in this unit did reach
high levels during remediation—669,270 (c/m3) after initial vacuum
and 105,882 (c/m3) after bagging debris—the decon levels never got
above 2,614 (c/m3). Our final sample taken was 66 (c/m3) and would
pass the Wonder Makers suggested post-remediation criteria.
An initial HEPA vacuum of the entire room.
Removal of all visibly contaminated drywall. This was
done with a Sawzall.
Another HEPA vacuuming of the entire room.
The wipe-down phase. All surfaces from drywall
to wood were scrubbed with green scouring pads
soaked in a RTU Microban solution and then wiped
down with cotton towels using the same solution.
Final HEPA vacuuming of the entire room.
Air samples were taken continuously during the process
both in the work area and just outside the door to the work
area. The purpose was to monitor what would typically escape
from a work area that was not under containment into the
unaffected area of a home or business.
The pre-remediation sample collected for this room was
554 (c/m3). The spore counts in this room were 128,630 (c/
m3) inside the work area during demo and 68,311 (c/m3)
outside the door. The counts were actually higher outside of
the work area during wipe down at 4,893 (c/m3) than they
were inside the work area at 3,913 (c/m3). Our final sample
from this room was 132 (c/m3) and would pass the Wonder
Makers’ recommended post-remediation criteria.
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ASSESSMENTS AND RECOMMENDATIONS
I was very satisfied with my findings and the sample data collected. After re-examining my goals and examining the data, I
made the following assessments:
“
•
We passed all post-remediation clearance tests. This was
not about passing any test, but I was glad we didn’t fail
anything. Room 1 mirrored how we do things at my company and I was hoping it would go well. Our technicians
were exposed to significantly less mold while working on
these units because of the engineering controls used. Also,
the spore counts decreased significantly after each step in
the remediation process.
•
The spore counts in Room 2 were as much as 20 times
higher during initial activity than they were during initial
testing. There was a large spike in the fungal count inside
the decon chamber as well, suggesting the strong possibility of cross-contamination. The counts inside the work
area of this unit proved beyond a shadow of a doubt that
engineering controls are of incredible importance to satisfy
the three priorities for fungal contamination work. I am glad
that this was only a one-time experiment. I would not want
to expose my technicians to spore counts that high on a
daily basis even in full PPE.
•
Room 3 was strictly a curiosity for me. I hear all the claims
about “miracle” chemicals, so I wanted to see if it would
make a difference if I switched from Microban to a hydrogen peroxide-based cleaner. The test data suggests that
the engineering controls and the actual process of the wipe
down make the difference. I still use hydrogen peroxidebased cleaners for clients who are sensitive to smells like
those associated with Microban and in some other situations, but I was satisfied that there was no real difference.
•
We have definitively disproven the “less than 10 visible sf” rule. I required my technicians to wear full PPE
regardless of the suggestions, and I’m glad that I did. The
spore counts inside the work area and outside the doorway of the room were high enough to potentially harm my
workers and the surrounding area. At some points, the
spore counts were much higher outside the work area
32 Cleaning & Restoration | January 2012 | www.restorationindustry.org
I DON’T EXPECT
OSHA OR THE EPA
TO REVISE OR
ABOLISH THE 10 SF
RULE AS A RESULT
OF THIS STUDY,
BUT I DO EXPECT
RESPONSIBLE
CONTRACTORS TO
EVALUATE THEIR
PROCEDURES.
than they were inside the work area. The 10 sf rule has
now been shown to be ineffective and dangerous to the
surrounding occupants, the structure and the people performing the remediation.
I undertook this project not just to help myself and other contractors, but also to shake things up. I was dissatisfied with what
I had seen in print, and I took it upon myself to prove some of it
wrong and get people talking. I don’t expect OSHA or the EPA to
revise or abolish the 10 sf rule as a result of this study, but I do
expect responsible contractors to evaluate their procedures. I also
expect those same contractors to use this to educate their clients
who are following that rule.
I have a special appreciation for the IICRC S520 after this; it is
the only guideline or standard to suggest that we should treat all
mold jobs the same regardless of size. I hope that all the agencies
responsible for publishing such standards and guidelines will take
a strong look at the data presented here and seriously consider
change. We have proven that engineering controls are paramount,
and that no matter the size of the job, it is imperative that each
project be taken seriously and treated the same.
Mark McLaughlin, CMP, is vice president of field operations for
Restore All, Inc. in Smyrna, Ga.
REPRINTED WITH PERMISSION FROM THE JANUARY 2012 ISSUE OF CLEANING & RESTORATION MAGAZINE,
PUBLISHED BY THE RESTORATION INDUSTRY ASSOCIATION.